Inquiries Procedures

As previously reported, Diclofenac a veterinary non-steroidal anti-inflammatory drug (NSAID), has been responsible for the devastating collapse of three species of the vultures on the Indian subcontinent. To place the devastation into perspective the Oriental White-backed vulture (Gyps bengelensis), which was the world’s more prominent bird species, had declined from a population peak of over ten million birds in 1990 to around 8000 in 2008 representing overall decline of over 99.9%. While the collapse of any wild-life population is of major concern, the decline of the vulture species on the Asian subcontinent highlighted the severe impact that veterinary pharmaceutical products could have on delicate eco-systems.

Although South Africa has been lucky in that diclofenac was never registered for local use, the Asian vulture crisis has, however, highlighted the plight of our local vulture populations which< are equally as troubled. While we can be proud to be home to nine vulture species, seven of these are listed as endangered on the IUCN red list, with even the once ubiquitous African White-backed vulture being listed as being threatened. Of these nine species, the Cape Griffon vulture still remains the most endangered vulture species and arguably the most endangered species in the country, with the last census listing only 2800 breeding pairs being present in the wild.

With the Southern African vulture species being in steady decline from the 1970’s, conservation organisations had initiated numerous support programmes including the management system of vulture restaurants. In this system, farmers were asked to place out carcasses from commercial farms and even trophy kills for the regularly feeding of vultures throughout the country. Whilst the programme has been highly successful with over 150 restaurants being known to be in operation, the accidental introduction of diclofenac into the Asian vulture food-chain has highlighted the potential of this system to introduce potentially dangerous veterinary drug into the vulture food-chain. This is of especially concern as recent studies have indicated that both the African white-backed vulture and the Cape Griffon vultures are extremely sensitive to the toxic effects of diclofenac.

Therefore in an aim to protect the remaining vultures from veterinary pharmaceuticals, the following is recommended when advising farmer of the disposal of carcasses;

· Avoid feeding carcasses that have received extensively treatment(s) prior to death.

· Treat all the NSAIDs as potentially toxicity. To date only meloxicam has been conclusively demonstrated to be safe in vultures.

· Carcasses from pentobarbitone euthanasia should be destroyed. In addition being the potential lethal to many carnivores, it should also be noted that package inserts clearly state that carcasses arising from pentobarbitone euthanasia may not be used for animal feeding.

· Avoid placing out wildlife carcasses that that die during or soon after immobilisation.

With the help of the veterinary profession, we can hopefully protect our vulture species from further declines.

(Published - November 2008)

Over servicing

OVER SERVICING

It is unethical and unprofessional to continue treatment of an animal when euthanasia is indicated and the veterinarian is fully aware that the animal will not recover from its illness.

(Published -December 1996)

Perverse Incentives

PERVERSE INCENTIVES

Council wishes to draw the profession’s attention to its adopted policy pertaining to perverse incentives and request that it is read with Rule 6 of the rules.

A practitioner should at all times act in the best interest of the patient and place the clinical need of the patient paramount. To this end a practitioner should always maintain professional autonomy, independence, and commitment to the appropriate professional and ethical norms. Any incentive or form of inducement which threatens such autonomy, independence, or commitment to the appropriate professional and ethical norms or which does not accord first priority to the clinical need of a patient, is unacceptable.

The policy statement applies to veterinarians in the public sector and those in the private sector who are contracted to provide services in the public sector. Examples in this sector are inter alia : over servicing patients and unnecessary referral to private practitioners; falsifying claims in order to increase statistics and selling drugs to private clients. It would be an offense to both offer an inducement and to accept it.

For the purpose of this policy statement the following words will have the meanings as indicated:

Valuable Consideration: the offer or acceptance of rewards, gifts or incentives to encourage sales or usage.

Trade: an act or an instance of buying and selling goods and services for financial gain.

Market related rental: as explained under note 8 of this policy statement.

Veterinarians may be involved for commercial purposes to trade in animal pharmaceuticals, feed and commodity products which form an integral and essential part of most practices. The supply of animal health products by veterinarians potentially adds important clinical value to these products. These aspects must be viewed as an integral part of the scope of practice of veterinarians. Veterinarians are in the best position to supply veterinary medicines and information regarding the rational use of essential veterinary medicines to developing farming communities;

Veterinarians may advertise the availability of veterinary and animal related products at veterinary practices. Income generated from the sale of these products by veterinarians are regarded as essential for the maintenance of many veterinary practices;

It is not permissible for a veterinary practitioner to engage in or advocate the preferential use of or prescribe any veterinary service or medicine or any product such as infant feeding products, vitamin supplements and products relating to weight control if any valuable consideration such as educational policies for a practitioner’s family, subsidized training (local or international), insurance policies, retirement annuities, or motor vehicle schemes is derived from such preferential use or prescription;

Veterinarians may refer patients to a registered veterinary facility, his / her own registered facility or to a registered member of the profession or to any health facility or institution e.g. (X-ray facilities, Cath lab, Path lab etc. only

If no valuable consideration is derived from such referral such as education policies for a practitioner’s family, subsidized training (local or inter national), insurance policies, retirement annuities, or motor vehicle schemes.

If no valuable consideration is derived from the referral of a patient to a specific practitioner or specialist (This does not include referral to facilities in which veterinarians have a financial interest as veterinarians own and practice from their veterinary clinics and hospitals which they are allowed to advertise.;)

It is not permissible for a veterinarian to permit or allow any immediate family member to own shares in any non-listed company which is involved in the manufacture of any medical device or medicine or any product such as infant feeding products, vitamin supplements and products relating to weight control;

It is not permissible for a veterinarian to permit or allow any members of the immediate family to own shares in any veterinary facility or veterinary service unless such facility or service operates as a listed company;

It is permissible for a veterinarian to own shares in a non-listed company or have a financial interest in an entity which owns or manages veterinary facilities or veterinary services or which manufactures, markets or distributes any veterinary devices, veterinary medicines or any products such as infant feeding products, vitamin supplements and products relating to weight control;

It is not permissible for a veterinarian to pay rentals in lease agreement which are not market related or accept payment or part-payment of room rental from such facilities. Market related rental is difficult to define.. A veterinary facility or veterinary service may wish to rent its consulting rooms at a particular rate. Such rental must, however, not be conditional on the practitioner to achieve a certain turnover, nor may it be selectively applied. All practitioners working in the veterinary facility must pay the same rental per m² ;

It is not permissible for a veterinarian to accept commission or any valuable consideration from any service in return for the purchase, sale or supply of any goods, substances or materials used by the practitioner in his or her practice or to pay commission or render any valuable consideration to any person for recommending patients;

Clients may be referred for the use of their animals for participating in drug trials, however no valuable consideration may be derived there from;

The veterinarian may not receive any valuable consideration for seeing a veterinary medical representative;

The veterinarian may not enter into a contract to work in a particular veterinary facility or veterinary service on the understanding that a practitioner generates a particular amount of revenue for such facility or service. A facility wherefrom a veterinary service is provided and equips a theatre, ward, etc. for a specific practitioner according to his / her specifications may well enter into a contractual agreement with such practitioner on the condition that such facility or service may not stipulate in the contractual agreement any turnover targets for the veterinary practitioner concerned;

The veterinary practitioner may not share fees with any person or practitioner who has not taken a commensurate part in the service for which the fees are charged; and

The veterinarian may not charge or receive fees for services not personally rendered, except for services rendered by another practitioner or person registered in terms of the Veterinary Act , with whom the practitioner is associated as a partner, shareholder or locum tenens.

his document has been adopted for the Veterinary Profession from the proposed policy statement of the Forum of Statutory Health Councils.

(Published -June 1999)

Perverse Incentives

Veterinarians who:

Over service patients;

Refer patients to private practitioners when treatment is not indicated;

Falsify claims in order to increase statistics and sell drugs to private clients;

Advocate the preferential use of or prescribe any veterinary service or medicine or any product and any valuable consideration is derived from such preferential use or prescription;

Pay or offer any commission to any person or colleague as a consideration for clients which are referred to you;

Accept any fee for the examination of an animal from both the buyer and the seller; and

Share fees with any person or practitioner who has not taken a commensurate part in the service for which the fees are charged.

Are jeopardising the autonomy, independence, or commitment to the professional and ethical norms becoming of the veterinary profession.

Any incentive or form of inducement which does not accord first priority to the clinical need of a patient is unacceptable and should be refrained from.

(Published - December 2000)

Identification of Veterinary Clinical Facilities

NEW RULES ON BOARDS

Identification Boards

This is a board ON THE PREMISES where the practice is situated; States the registered name of the practice; It may contain a logo; There is no restrictions on size or letter size; Consulting hours are allowed to appear on the identification board; and there is no restriction on the number of boards.

Direction Boards

This is a board situated away from the practice indicating the direction to follow to the practice; It must comply with the municipal/provincial regulations governing direction boards; There is no limitation on the number or size of boards and the content of the boards shall be limited to the registered name of the Veterinary Hospital, Clinic, Consulting Room, and where necessary, a direction arrow.

Sign Boards

This is an advertising board situated away from the practice containing information relating to the practice i.e. registered name, address and telephone numbers. Sign boards may be erected where the practice is situated in a complex and the circumstances justify a sign board. THE USE OF THIS BOARD IS TO BE APPROVED BY COUNCIL.

(Published -June 1997)

REGISTRATION OF FACILITY NAMES

CHANGES TO THE GUIDELINES

Geographical, street, suburb and district names are acceptable. Names, which imply too wide a practice area, e.g. Natal Veterinary Hospital, are not permitted. Suburb and street names are given preference, and town names are granted only in exceptional circumstances.

The use of " made-up" names, including those, which contain the prefix or suffix "vet" (e.g. Citivet or Medvet), are permitted, provided that such a name is followed by " veterinary hospital/clinic/consulting room/ or centre". All applications for made-up names are referred to Council for approval.

Duplication of names should be avoided with the exception of common street or suburb names in different towns, which are further than 50 km apart. The duplication of " made-up" names will not be permitted.

After-hours facilities can be registered. An after-hours facility is a facility, which complies with the minimum standards for a hospital, which operates outside of normal working hours for veterinary practices whereto after-hours work is referred, i.e. at night, Saturday afternoons, Sundays and public holidays. ( The onus rests on the referring practice to ensure that veterinary attention is available outside of the operating hours of the after-hours facility.)

Species practices, e.g. bird or equine practices can be registered. Organ and discipline practices should be registered provided that:

such a practice is registered in the name of a registered specialist in the organ/discipline involved;

should such a practice be sold to a non-specialist, the name would have to change;

a specialist should be on duty at all times at such a practice, e.g. where it is necessary for a locum to be employed at such a practice, this locum must be a specialist in the applicable field;

general veterinary work should be permitted to be performed at such a practice; and

such a practice should not be obliged to operate on a referral basis.

Emergency facilities can be registered. An emergency facility is a facility which complies with the minimum standards for a hospital at which a veterinarian is present, and prepared to attend to emergencies with minimum delay, at all times.

Centre facilities can be registered. A centre is a facility shared by a minimum of two veterinary specialist disciplines, each of which is headed by a registered specialist in the appropriate fields, and has such a specialist present. Appropriately equipped facilities for the specialist disciplines must be available at all times. Subject to these requirements, general practitioners may operate from such facilities.

Only names ending in " hospital", " clinic", " consulting room" or " centre" are registerable. There is a cross- referencing between names of facilities and close corporations.